Interpretation of the Convention. It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD-Model Convention on Income and on Capital shall generally be expected to have the same meaning as expressed in the OECD Commentary thereon. The understanding in the preceding sentence will not apply with respect to the following:
Interpretation of the Convention. It is understood that the OECD and UN Model Commentaries – as they may be revised from time to time – constitute a means of interpretation in the sense of Vienna Convention of 23 May 1969 on the Law of Treaties as far as the provisions of this Convention correspond to those Model Conventions and subject to any contrary interpretations in this Protocol and any contrary interpretation agreed to by the competent authorities after the entry into force of this Convention or any future reservations or observations to the OECD and UN Model or their Commentaries by either Contracting State.
Interpretation of the Convention. The OECD Commentary - as it may be revised from time to time - constitutes a means of interpretation in the sense of Article 32 of the Vienna Convention of 23 May 1969 on the Law of Treaties.
Interpretation of the Convention. It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD-Model Convention on Income and on Capital or the United Nations Model Double Taxation Convention between Developed and Developing Countries with respect to Taxes on Income and on Capital shall generally be expected to have the same meaning as expressed in the OECD or UN Commentary thereon. The understanding in the preceding sentence will not apply with respect to any contrary interpretation agreed to by the competent authorities after the entry into force of the Convention. The Commentaries - as they may be revised from time to time - constitute a means of interpretation in the sense of the Vienna Convention of 23rd May 1969 on the Law of Treaties. In case of any divergence in the interpretation as expressed in the commentaries of the OECD and the UN Model, a common interpretation would have to be sought by mutual agreement according to Article 25, if necessary.
Interpretation of the Convention. It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD Model Convention on income and on capital shall generally be expected to have the same meaning as expressed in the OECD Commentaries thereon. The Commentaries –as they may be revised from time to time—constitute a means of interpretation in the sense of the Vienna Convention of 23 May 1969 on the Law of Treaties. In witness whereof the undersigned, duly authorised thereto, have signed this Protocol. Done at ................, on the………. day of............. in two originals, in the Spanish, Croatian and English languages, all the texts being equally authentic. In case of divergence between any of the texts, the English text shall prevail.
Interpretation of the Convention. It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD Model Convention on income and on capital shall generally be expected to have the same meaning as expressed in the OECD Commentaries thereon. The Commentaries – as they may be revised from time to time – constitute a means of interpretation in the sense of the Vienna Convention of 23 May 1969 on the Law of Treaties.
Interpretation of the Convention. It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD Model Convention on income and on capital shall generally be expected to have the same meaning as expressed in the OECD Commentaries thereon. The Commentaries - as they maybe revised from time to time - constitute a means of interpretation in the sense of the Vienna Convention of 23 May 1969 on the Law of Treaties. To Article 10 paragraph 6: If, and so long as, a Convention with respect to taxes on income and on capital is effective between Kazakhstan and a present member of the Organisation for Economic Co-operation and Development, which convention does not provide for an additional tax such as that provided for in paragraph 6 of Article 10 of this Convention, the additional tax mentioned therein shall not be levied upon enterprises resident in Austria. To Articles 11 and 12: The Contracting States agree that where Kazakhstan agrees to a lower rate of tax than 10 per cent in paragraph 2 of Article 11 or in paragraph 2 of Article 12 in any Convention between Kazakhstan and a third State which is a member of the Organisation for Economic Co-operation and Development, and that Convention enters into force either before or after the date of entry into force of this Convention the competent authority of Kazakhstan shall notify the competent authority of Austria of the terms of the relevant paragraph in the Convention with that third State immediately after the entry into force of that Convention and such lower rate of tax shall be substituted for 10 per cent in paragraph 2 of Article 11 or paragraph 2 of Article 12, as the case may be, of this Convention with effect from the date of entry into force of that Convention, or of this Convention, whichever is the later. IN WITNESS WHERE OF the Undersigned, being duly authorized thereto, have signed this Protocol. DONE in duplicate in 2004 this 10 day of September in the Kazakh, German, Russian and English languages, all texts being equally authentic. In the case of divergence between the texts the English text shall prevail. For the Republic of Kazakhstan For the Republic of Austria
Interpretation of the Convention. In the interpretation and application of the provisions of this Convention regard shall be had to its international character and to the need to promote uniformity. Part II - Liability of the carrier
